DAQ-2024-008566

1

DAQC-579-24
Site ID 10919 (B4)

MEMORANDUM

TO: STACK TEST FILE – KIMBERLY-CLARK WORLDWIDE INCORPORATED –
Ogden Plant

THROUGH: Rik Ombach, Minor Source Oil and Gas Compliance Section Manager

FROM: Kyle Greenberg, Environmental Scientist

DATE: June 13, 2024

SUBJECT: Sources: Forming Baghouses #1, #2, #3, #4, and #6; Collector Baghouses
#5 and #8
Location: Weber County, UT
Contact: Mike Jones: 801-786-2318
Tester: TETCO
Site ID #: 10919
Permit/AO #: DAQE-AN109190023-23, dated October 27, 2023
Subject: Review of Pretest Protocol received June 10, 2024

On June 10, 2024, DAQ received a protocol for testing of Forming Baghouses #1, #2, #3, #4, and #6 and
Collector Baghouses #5 and #8 at the Kimberly-Clark Ogden Plant in Weber County, UT. Testing will be
performed the week of September 30, 2024, to determine compliance with the emission limits found in
condition II.B.3 of Approval Order DAQE-AN109190023-23.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses: OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate: OK
3. RM 3 used to determine dry molecular weight of the gas stream: OK
4. RM 4 used to determine moisture content: OK
5. RM 5 used to determine particulate emissions: OK

DEVIATIONS: None.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: It is recommended that the methods proposed in this pretest
protocol be accepted for the determination of compliance for the
above listed units.

ATTACHMENTS: Kimberly-Clark Test Notification Letter, TETCO Pretest
Protocol.

COMPLIANCE EMISSION TESTING PROTOCOL
FOR TOTAL PARTICULATE EMISSIONS
KIMBERLY-CLARK, OGDEN, UTAH

FORMING BAGHOUSES #1, #2, #3, #4 AND #6
COLLECTOR BAGHOUSES #5 AND #8

Project Organization and Responsibility

The following personnel and the testing contractor are presently anticipated to be involved in the
testing program. The Utah Department of Environmental Quality, Division of Air Quality
(DAQ) and EPA may have their own personnel to observe all phases including the process.

Company
Contacts
Kimberly-Clark Corp. Mike Jones 801 786-2318
2010 North Rulon White Blvd.
Ogden, Utah 84404

TETCO Dean Kitchen 801 492-9106
391 East 620 South
American Fork, Utah 84003

Facility Location and Description

These tests will be conducted to determine the PM10 emissions from six (7) baghouses at
Kimberly-Clark’s Ogden plant. The baghouse exhaust stacks are located on the building roof
and are identified as Forming Baghouses #1, #2, #3, #4, #6 and Collector Baghouses #5 and #8.

Test Objective

This test is being conducted to comply with the requirements of the Kimberly-Clark’s Approval
Order number DAQE-AN0109190023-23. This permit requires testing for particulate emissions
from each baghouse exhaust every five years. EPA Method 5 will be used with all particulate
matter captured counted as PM10. Testing procedures will include accumulating process and
production data.

Previous testing on these baghouses have demonstrated that the gas is ambient air. Stack
temperatures are a factor of the season and weather and not process oriented. With this
consideration it is proposed that condensable particulate matter testing not be completed on these
sources.

2
Special Conditions

The five Forming Baghouses (#1, #2, #3, #4 and #6) are identical in configuration and do not
meet the minimum requirement that the sampling ports be at least two diameters downstream of
the nearest flow disturbance. The inside diameter of these stacks is 36 inches. There are 62
inches (1.7 diameters) of unrestricted flow before the sampling ports and 18 inches (0.5
diameters) of unrestricted flow after the ports. See Facility Schematic Representation in
Appendix A. In order to meet the EPA specification of undisturbed flow before the sampling
ports, egg crate straightening vanes were installed 24 inches below the sample ports as described
in Method 5D. The straightening vanes cell size is 6 inches.

Test Schedule

It is planned to complete this testing project the week of September 30, 2024. The testing crew
will take preliminary measurements prior to testing each exhaust stack. More than one stack
may be tested at the same time but simultaneous testing is not a requirement of this protocol.

If necessary, a pretest meeting may be scheduled by EPA, DAQ, or Kimberly-Clark.

Operational Data and Instrumentation

Kimberly-Clark will be responsible for recording production data. The following table identifies
which manufacturing lines are controlled by each baghouse.

Manufacturing Line

Baghouse #

Lines 1 and 2

Forming Baghouse # 1

Lines 3 and 4

Forming Baghouse # 2
Lines 5 and 6 Forming Baghouse # 3

Lines 7 and 8

Forming Baghouse # 4

Reclaim

Forming Baghouse # 6

Baghouses 1-4 and 6 bottoms

Collector Baghouse # 5 or # 8

Testing may be conducted when one or both diaper lines served by the baghouse are in
operation. All operational and instrumentation data will be made available to DAQ personnel.

3

Site Access

The test site is on the building roof and is accessed via OSHA approved stairs or ladders.

Test Procedures

Three test runs will be completed on the each exhaust stack. Stack testing will follow EPA
Method 5 as specified in 40 CFR 60, Appendix A. Detailed procedures are as follows:

1. The stack diameters of Forming Baghouse #1-#4 and #6 are 36 inches. The ports are
located 18 inches (0.5 diameters) upstream from the next disturbance and 24 inches (4.0
diameters) downstream from the straightening vanes. Twelve traverse points will be
sampled from each port for a total of 24 sample points.

The stack diameters of Collector Baghouses #5 and #8 are 24 inches. The sampling ports
are located 30 inches (1.25 diameters) upstream from the next disturbance and 48 inches
(2.0 diameters) downstream from the last disturbance. Twelve traverse points will be
sampled from each port for a total of 24 sample points.

2. EPA Method 2 will be used to determine the gas stream velocity. In connection with
Method 2, type "S" pilot tubes will be used with a factor of .84. Dual inclined/vertical
manometers with graduations in .01 of an inch of water will be used. If the flows are
below 0.05 inches of water a more sensitive manometer may be used as per Method 2,
section 6.2. The graduation marks on it are .005 inches of water. Direction of gas flow
will be checked for gas cyclonics prior to testing. If the average deviation is over 20
degrees, then straightening vanes will be installed or other arrangements agreeable to
DAQ will be made.

3. Each test run time will be 2 hours (120 minutes). The sample volume will be at least 30
dscf for each test run.

4. The exhaust gas is ambient air. TETCO will use a dry molecular weight of 28.84 lb/lb
mole (20.0 % O2, 79.1 % N2) in all calculations.

5. Method 4 will be used to determine the gas stream moisture content

6. A barometer will be used to measure the barometric pressure. It is periodically checked
against a mercury barometer. Prior to testing it will be checked to assure an accurate
barometric pressure.

7. Calibration data is provided with this protocol. Equipment calibrations that fall past due
prior to the test dates, will be recalibrated prior to being used. Any calibrations not

4
included with this protocol, such as new or additional equipment, will be made available
to DAQ representatives upon request.

8. The glass fiber filters that will be used meet or exceed the requirements specified in EPA
Method 5.

9. The probe liners are of 316 grade stainless steel.

10. Preparation and clean up by the contractor will be performed in the contractor's testing
trailer. Laboratory work and analysis will be performed by the testing contractor as soon
as possible after all tests have been completed.

11. If maintenance or operating problems arise during the test, the test may be stopped. This
determination will be made by Kimberly-Clark representatives and operating personnel in
consultation with DAQ representatives.

12. Verbal results will be reported to Mike Jones of Kimberly-Clark. The written report will
follow within 30 days following the completion of the test.

Estimates of Test Parameters

Estimates of stack exhaust parameters are given below. These values are estimates only and are
not intended to reflect permitted values.

Source

Velocity (fpm)

Temperature F

Moisture %

Forming Baghouse #1

2,500

100

1

Forming Baghouse #2

2,500

105

1
Forming Baghouse #3 2,500 105 1

Forming Baghouse #4

3,400

105

1

Forming Baghouse #6

2,700

100

1

Collector Baghouse #5

1,900

95

1

Collector Baghouse #8

2,200

100

1

5
Potential Hazards

Moving Equipment – No Chemical - No
Hot Equipment – No Other - No

Quality Assurance

All testing and analysis in these tests will be conducted according to Methods 1-5 and
appropriate sections of the EPA Quality Assurance Handbook for Air Pollution Measurement
Systems Vol. III.

Reporting

Reporting will be prepared by the testing contractor according to EPA Quality Assurance
Guidelines. A complete copy of raw data and test calculations summary will be included in the
reports. All process and production data will be recorded and retained by Kimberly-Clark
personnel for inspection by DAQ and EPA, if requested.

6
Appendix A

Source Schematics
Facility:
Stack Identification:

24"
Straightening
Vanes
Kimberly-Clark
1
105-115
2,200-3,300
Forming Baghouses #1-#4 and #6
18"
62"
a: Distance upstream from next disturbance, inches
b: Distance downstream from last disturbance, in.
10'g: Distance of Sample Level to ground, feet
Diaper ManufactureType:
Number of Ports
Process
Type:
Control Unit
2
Estimated Temperature, oF
Estimated Velocity, fpm
36"
Baghouse
 Stack Inside Diameter, inches
Estimated Moisture, percent
a
g
b
Figure 1. Facility Schematic Representation
Facility:
Stack Identification:
∅
Estimated Velocity, fpm
24"
Baghouse
∅: Stack Inside Diameter, inches
Estimated Moisture, percent
107
1,500
α: Distance upstream from next disturbance, inches
β: Distance downstream from last disturbance, in.
Diaper Manufacture Type:
Number of Ports
Process
Type:
Control Unit
2
Estimated Temperature, oF
12'γ: Distance of Sample Level to roof, feet
Kimberly-Clark
1
Collector Baghouse #5 and #8
30"
48"
α
γ
β
Figure 2. Facility Schematic Representation

7
Appendix B

Calibration Data
METHOD 5 DRY GAS METER CALIBRATION USING CRITICAL ORIFICES
1) Select three critical orifices to calibrate the dry gas meter which bracket the expected operating range.
2) Record barometric pressure before and after calibration procedure.
3) Run at tested vacuum (from Orifice Calibration Report), for a period of time
necessary to achieve a minimum total volume of 5 cubic feet.
4) Record data and information in the GREEN cells, YELLOW cells are calculated.
TECHNICIAN:INITIAL FINAL AVG (Pbar)
DATE:12/21/2023 METER SERIAL #:300315 BAROMETRIC PRESSURE (in Hg):25.55 25.65 25.60 IF Y VARIATION EXCEEDS 2.00%,
METER PART #:Console 3 CRITICAL ORIFICE SET SERIAL #:1453S EQUIPMENT ID #:ORIFICE SHOULD BE RECALIBRATED
K'TESTED TEMPERATURES °F ELAPSED
FACTOR VACUUM DGM READINGS (FT3)AMBIENT DGM INLET DGM OUTLET DGM TIME (MIN)DGM DH (1)(2)(3)Y
ORIFICE #RUN #(AVG)(in Hg)INITIAL FINAL NET (Vm)INITIAL FINAL INITIAL FINAL AVG q (in H2O)Vm (STD)Vcr (STD)Y VARIATION (%)DH@
1 0.8137 10 100.418 105.533 5.115 71 82 87 75 78 80.5 4.759 3.00 4.3128 4.3028 0.998 1.740
2 0.8137 10 105.533 110.912 5.379 72 85 89 78 81 83.3 5.012 3.00 4.5125 4.5278 1.003 1.735
3 0.8137 10 110.912 117.512 6.600 72 90 93 80 83 86.5 6.081 3.00 5.5038 5.4935 0.998 1.724
AVG = 1.000 -0.18
1 0.5317 11 83.911 89.115 5.204 69 69 75 66 70 70.0 7.477 1.22 4.4522 4.4262 0.994 1.675
2 0.5317 11 89.115 94.226 5.111 71 74 79 71 74 74.5 7.282 1.22 4.3358 4.3027 0.992 1.668
3 0.5317 11 94.226 99.407 5.181 72 79 83 74 75 77.8 7.332 1.22 4.3686 4.3281 0.991 1.661
AVG = 0.992 -0.91
1 0.3307 13 117.962 123.015 5.053 74 90 89 82 84 86.3 11.603 0.45 4.1851 4.2521 1.016 1.561
2 0.3307 13 123.015 128.053 5.038 75 88 89 84 86 86.8 11.514 0.45 4.1688 4.2155 1.011 1.563
3 0.3307 13 128.053 133.107 5.054 75 89 90 86 87 88.0 11.508 0.45 4.1725 4.2133 1.010 1.559
AVG = 1.012 1.08
AVERAGE DRY GAS METER CALIBRATION FACTOR, Y = 1.001
AVERAGE DH@ = 1.654
(1)=Net volume of gas sample passed through DGM, corrected to standard conditions
K1 =17.64 oR/in. Hg (English), 0.3858 oK/mm Hg (Metric)
Tm =Absolute DGM avg. temperature (oR - English, oK - Metric) DH@ = 0.75 q DH Vm(std)
Vcr(std) Vm
(2)=Volume of gas sample passed through the critical orifice, corrected to standard conditions
Tamb =Absolute ambient temperature (oR - English, oK - Metric)
Average K' factor from Critical Orifice Calibration REFERENCE IN OUT
(3)=DGM calibration factor 32 33 32
62 63 63
204 205 205
TEMPERATURE SENSORS oF
2024 Pre-Calibration
Console #3
30
19
12
D Kitchen
ENVIRONMENTAL SUPPLY COMPANY
USING THE CRITICAL ORIFICES AS CALIBRATION STANDARDS:
The following equations are used to calculate the standard volumes of air passed through the DGM, V m (std), and the critical orifice,
Vcr (std), and the DGM calibration factor, Y. These equations are automatically calculated in the spreadsheet above.
()2 ()
METHOD 5 DRY GAS METER CALIBRATION USING CRITICAL ORIFICES
1) Select three critical orifices to calibrate the dry gas meter which bracket the expected operating range.
2) Record barometric pressure before and after calibration procedure.
3) Run at tested vacuum (from Orifice Calibration Report), for a period of time
necessary to achieve a minimum total volume of 5 cubic feet.
4) Record data and information in the GREEN cells, YELLOW cells are calculated.
TECHNICIAN:INITIAL FINAL AVG (Pbar)
DATE:12/7/2023 METER SERIAL #:68092 BAROMETRIC PRESSURE (in Hg):25.65 25.65 25.65 IF Y VARIATION EXCEEDS 2.00%,
METER PART #:Console 6 CRITICAL ORIFICE SET SERIAL #:1453S EQUIPMENT ID #:ORIFICE SHOULD BE RECALIBRATED
K'TESTED TEMPERATURES °F ELAPSED
FACTOR VACUUM DGM READINGS (FT3)AMBIENT DGM INLET DGM OUTLET DGM TIME (MIN)DGM DH (1)(2)(3)Y
ORIFICE #RUN #(AVG)(in Hg)INITIAL FINAL NET (Vm)INITIAL FINAL INITIAL FINAL AVG q (in H2O)Vm (STD)Vcr (STD)Y VARIATION (%)DH@
1 0.8137 10 204.981 213.255 8.274 71 71 84 69 71 73.8 7.75 2.90 7.0764 7.0215 0.992 1.700
2 0.8137 10 213.255 221.823 8.568 71 82 88 70 72 78.0 8.00 2.90 7.2699 7.2481 0.997 1.686
3 0.8137 10 221.823 226.926 5.103 71 86 88 72 72 79.5 4.75 2.90 4.3178 4.3035 0.997 1.682
AVG = 0.995 0.11
1 0.5317 11 184.867 190.097 5.230 69 72 80 69 71 73.0 7.50 1.20 4.4576 4.4485 0.998 1.635
2 0.5317 11 190.097 196.569 6.472 65 78 82 70 71 75.3 9.25 1.20 5.4930 5.5074 1.003 1.616
3 0.5317 11 196.569 204.797 8.228 65 79 84 70 72 76.3 11.75 1.20 6.9704 6.9959 1.004 1.613
AVG = 1.001 0.72
1 0.3307 13 227.035 233.113 6.078 72 83 80 72 72 76.8 13.75 0.43 5.1329 5.0582 0.985 1.509
2 0.3307 13 233.113 240.071 6.958 72 78 79 71 71 74.8 15.75 0.43 5.8980 5.7939 0.982 1.515
3 0.3307 13 240.071 245.134 5.063 72 78 89 71 71 77.3 11.50 0.43 4.2717 4.2305 0.990 1.508
AVG = 0.986 -0.83
AVERAGE DRY GAS METER CALIBRATION FACTOR, Y = 0.994
AVERAGE DH@ = 1.607
(1)=Net volume of gas sample passed through DGM, corrected to standard conditions
K1 =17.64 oR/in. Hg (English), 0.3858 oK/mm Hg (Metric)
Tm =Absolute DGM avg. temperature (oR - English, oK - Metric) DH@ = 0.75 q DH Vm(std)
Vcr(std) Vm
(2)=Volume of gas sample passed through the critical orifice, corrected to standard conditions
Tamb =Absolute ambient temperature (oR - English, oK - Metric)
K' = Average K' factor from Critical Orifice Calibration REFERENCE IN OUT
(3)=DGM calibration factor 32 33 32
72 73 73
203 203 202
TEMPERATURE SENSORS oF
2024 Pre-Calibration
Console #6
30
19
12
Reed Kitchen
ENVIRONMENTAL SUPPLY COMPANY
USING THE CRITICAL ORIFICES AS CALIBRATION STANDARDS:
The following equations are used to calculate the standard volumes of air passed through the DGM, V m (std), and the critical orifice,
Vcr (std), and the DGM calibration factor, Y. These equations are automatically calculated in the spreadsheet above.
()2 ()
Type S Pitot Tube Inspection Data
Date:Pitot Tube Identification:
Technician:
Dt=0.375 Is PA = PB ?
Is 1.05 • Dt  PA & PB  1.50 • Dt ?
PA = 0.455
PB =0.455
a1 < 10o a1 = o
a2 < 10o a2 = o
b1 < 5o b1 = o
b2 < 5o b2 = o
Z  0.125 in.Z = in.
W W  0.03125 in.W = in.
W > 3 inches W = in.
Z > 3/4 inch Z = in.
Y ≥ 3 inches Y = in.
The pitot tube meets the specifications for a calibration factor of 0.84?Yes
Reference:
Temperature
Source Reference Sensor
(Medium)(oF)(oF)
Probe AIR 71 71
AIR 71 70
ICE WATER 33 34
BOIL WATER 204 204
SILICONE OIL
1/3/2024 27 G-2
X. Dang
in.
0.016
0
0
2
2
0
in.
in.
Yes
Yes
0.016
6.875
0.875
3 3/4
Heat Check 248
Temperature Sensor Calibration
1
1
0Stack
Omega CL3512A
Probe Yes
Yes
Continuity Check
Temperature Temperature
Difference
(oF)
b2
b1
B
A
w
Dt
PA
PB
Type S Pitot Tube Inspection Data
Date:Pitot Tube Identification:
Technician:
Dt=0.375 Is PA = PB ?
Is 1.05 • Dt  PA & PB  1.50 • Dt ?
PA = 0.479
PB =0.479
a1 < 10o a1 = o
a2 < 10o a2 = o
b1 < 5o b1 = o
b2 < 5o b2 = o
Z  0.125 in.Z = in.
W W  0.03125 in.W = in.
W > 3 inches W = in.
Z > 3/4 inch Z = in.
Y ≥ 3 inches Y = in.
The pitot tube meets the specifications for a calibration factor of 0.84?Yes
Reference:
Temperature
Source Reference Sensor
(Medium)(oF)(oF)
Probe AIR 64 64
AIR 64 63
ICE WATER 33 33
BOIL WATER 204 205
SILICONE OIL
Heat Check 248
Temperature Sensor Calibration
1
0
1Stack
Omega CL3512A
Probe Yes
Yes
Continuity Check
Temperature Temperature
Difference
(oF)
0
in.
in.
Yes
Yes
0.002
4
0.875
3 3/4
1/16/2024 38 G
M. McNamara
in.
0.018
1
1
2
1
b2
b1
B
A
w
Dt
PA
PB
Date:1/2/24 Calibrator:Reference:
Temperature Temperature
Source Difference
(Medium)(oF)
Water 0
Water -2
Water 0
Water -2
Water 0
Water -1
Water 0
Water -2
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water -1
Water 0
Water -1
Water 0
Water 0
Water 0
Water 0
Water 0
Water -1
Water 0
Water -1
Water 0
Water 0
Water 1
Water 0
Water 0
Water -2
Water 0
Water -1
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
Water 0
202
33 33
Impinger Out K 33 33
203 203
33 33
Impinger Out J
Impinger Out H
Impinger Out I
33
203
33
203
33
203
33
203
203
201
33
G
H
Oven (3)33 33
203 203
Oven (4)33
203
Oven 33 33
203 203
Oven 33 33
33
203 202
Oven (3)
A
201203
33
Oven (3)33 33
Oven (4)
Thermocouple
Location
203 201
Impinger Out F 33 33
203
203
203
203 202
203 203
33
33
Impinger Out G
203 201
Oven (3)33
203 203
33 33
203Oven (4)
203
Impinger Out D 33 33
203 203
Impinger Out E 33 34
203 203
203
33 33
203Impinger Out B
Impinger Out C 33 33
203 202
202
Impinger Out A 33 33
203
Oven (3)
Oven (4)
TETCO
Sample Box Temperature Sensor Calibration
B
C 203 203
33 33
33 33
203
33 33
Xuan N. Dang Omega CL3512A
Unit ID Reference
(oF)
Sensor
(oF)
Temperature
33
D
E
Oven 33 33
203 202F
Oven (4)
Balance Denver Instruments, Model A-250, SN B045284
Weights Used Troemner Weight Set,
SN 98-115146
Certified Weight Measured Weight Difference
grams grams grams
0.1000 0.1000 0.0000
0.5000 0.5000 0.0000
1.0000 1.0000 0.0000
10.0000 10.0000 0.0000
50.0000 50.0001 -0.0001
100.0000 100.0000 0.0000
120.0000 120.0001 -0.0001
150.0000 150.0000 0.0000
Technician Michael McNamara
TETCO
Annual Balance Calibration Check
Date 1/23/24